C h a n g e o f N a m e

IN THE MATTER OF THE CHANGE OF NAME OF YAP EK SIU vs.
REPUBLIC
G.R. No. L-25437, April 28, 1969
"It must not be forgotten that the State has an
interest in the names borne by individuals and
entities for purposes of identification, and that a
change of name is a privilege and not a matter of
right." - Justice J.B.L Reyes (1957)
Second, it would be confusing if after he has been using his present
name all the while in both his personal and business dealings, he would
thereafter be known differently.
Third, it is not enough that his Filipino playmates from his childhood
days have called him William.
Lastly, the plea that a sense of filial respect, his father having been
authorized to use the name Tanchon, is not that persuasive.

DOCTRINE:
1. Our Civil Code recognizes that a person may change his name or
surname if allowed to do so by proper judicial authorization and that
it should be warranted by reasonable or justifiable cause.
2. Further, changing of name is, however, a privilege and not a right
conferred on him.

FACTS:
Yap Ek Siu instituted an action in the CFI of Negros Oriental seeking
to change his name to William Tanchon because of the following
circumstances:
1. that since his childhood days, his Filipino playmates called him
William;
2. that he also desires to have his family name of Yap changed to
Tanchon in due respect to his father named Pio Tanchon who
has been authorized by the CFI to use said name per its
Decision;
3. that said father is a naturalized Filipino citizen in accordance
with the Decision of this Court and was issued a Certificate of
Naturalization
4. that he makes it plain and clear that he is still a Chinese citizen,
and that his intention in filing this petition for change of name is
not to escape or evade his civil obligations
Notwithstanding an opposition filed by the City Fiscal (on behalf of
the Republic), the lower court granted such petition.

ISSUE:
Did the petitioner satisfy the standard which would warrant a
change of name?

RULING:
No.
In the case of Yu Chi Han v. Republic, the Court that the State has an
interest in the names borne by individuals and entities for purpose of
identification and that a change of name is a privilege and not a matter of
right, so that before a person can be authorized to change his name given
him either in his certificate of birth or civil registry he must show proper
or reasonable cause, or any compelling reason which may justify such
change. Otherwise, the request should be denied
The following may be considered, among others, as proper and
reasonable causes that may warrant the grant of a petition for change of
name:
(1) when the name is ridiculous, tainted with dishonor, or is
extremely difficult to write or pronounce;
(2) when the request for change is a consequence of a change of
status, such as when a natural child is acknowledged or
legitimated; and
(3) when the change is necessary to avoid confusion
In the present case, he has not proven that his name is ridiculous, or
tainted with dishonor or extremely difficult to write or pronounce.
Neither has he claimed that he wants to change his name by reason of a
change in his status. And there is nothing in the record that would show
that petitioner's continuous use of his present name would cause
confusion. In fact, his allegations are on the contrary.
First, he admitted that he "is still a Chinese citizen".